OIG Tells CMS: Audit POS 11 Claims

If you’re doing outpatient surgery in a facility, make sure you’re reporting the right place-of-service (POS) code. After finding 83 percent of a sample of POS 11 claims miscoded and overpaid in 2009, the Office of the Inspector General (OIG) recommended several actions to the Centers for Medicare & Medicaid Services (CMS) in a Sept. 7 report. These include audits and recovery.

The OIG found in its sample of 100 claims that only 17 services were coded correctly. The other 83 services were reported as nonfacility POS codes when the services were actually performed in hospitals or ambulatory surgery centers (ASCs). Incorrect coding resulted in overpayments totaling $2,979.

Based on the number of claims with POS 11, the OIG estimates Medicare contractors overpaid physicians $9.5 million during 2009.

“We attribute the overpayments to internal control weaknesses at the physician billing level and to insufficient postpayment review at the Medicare contractor level to identify potential place-of-service (POS) coding errors,” the OIG states in the report.

The OIG recommends CMS have its contractors:

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  • Recover the $2,979 in overpayments for the sampled services.
  • Immediately reopen claims associated with 494,029 services not sampled, review the information on these claims, and work with providers to recover any overpayments, which the OIG estimates as $9,498,443.
  • Strengthen their education processes and re-emphasize to physicians and their “billing agents” the importance of correctly coding the POS and the need for internal controls to prevent Medicare billings with incorrect POS.
  • Work with program safeguard contractors and, if necessary to coordinate Part A and Part B data matches, with other Medicare contractors to: (1) develop a data match that will identify physician services at high risk for POS miscoding; and, (2) recover any identified overpayments.

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9 Responses to “OIG Tells CMS: Audit POS 11 Claims”

  1. Jamie Parker says:

    Does anyone know if this applies to all Service Locations of 11? What about Physical Therapy clinics?

    thanks!

  2. Jamie Parker says:

    You can reply to me at jamie@gojamie.com about PT clinics. Thanks!

  3. Jennifer Scott says:

    I don’t get it! According to Medicare, I am supposed to bill out patient surgery in a Ambulatory Center with a 22 POS code. According to everyone else, I should be billing out with the 24 POS code. Medicare won’t pay with the 22 POS code but the others will. Just don’t get it????

  4. Teresa says:

    @Jennifer…I’m not sure where you read POS 22 for ASC. I understand that all services performed in the ASC are billed under POS 24. POS 22 is for outpatient surgery not associated with ASC.

  5. Lisa says:

    Our office does ablations, vaginal plasty different types of surgeries that require an anestheologist. What POS would be approperate?

    Thank you,
    Lisa

  6. Michael CPC says:

    Lisa- if the procedure is done in your physician’s office, the POS is 11. If the procedure is done in the outpatient surgery department in the hospital, then the POS 22. A free standing surgery center is POS 24. One way to check if it is a outpatient or ASC is to see if the NPI of the ASC is different than that of the hospital. If it is, then you have a for profit ASC.

  7. Aurora G Alvarez says:

    Be in POS 22 (Hospital outpatent), or POS 24 ( ASC ) it can never be billed as POS 11.

  8. Munnette says:

    If the physician is renting a room, C-arm, and paying staff in an ASC after the ASC is closed to do procedures is this considered POS 11?

  9. Cheryl says:

    The place of service would be 24 ASC not 11.

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